Voluntary Use of Elastomeric Respirators
Do you allow workers to voluntarily use respirators in the workplace?
I had someone ask me a great question last week during a PPE webinar that I did. They asked if half- and/or full-face respirators required medical evaluations if they were only worn voluntarily. It generated some great discussion, so I thought it'd be worth sharing to the community.
The key thing here is the TYPE of respirator being worn. If it was a filtering facepiece respirator (e.g., N95, dust mask), then you could technically get away with just ensuring the FFR doesn't create a hazard in itself, then simply giving them their required copy of 1910.134, Appendix D. However, for all other types of respirators, it's a different story.
If you allow the use of elastomeric respirators in the workplace for voluntery use, you are still required to implement the elements of your written respiratory protection program necessary to ensure that the employee voluntarily using the respirator is medically fit to do so, and that the respirator is cleaned, stored, and maintained so that its use does not present a health hazard to the user. The preamble to 1910.134 explains that medical evaluation is NECESSARY, even for voluntary use of negative pressure (tight-fitting) respirators, because they impose a significant physiologic burden on the respirator user, and it is crucial to determine that the user can withstand that burden without suffering adverse health consequences.
Comments (6)
Yes, Drew. You hit all the points. We have two sand mines in West Texas, and the topic comes up during allergy season. Something always seems to be blooming in the desert. We have a respiratory protection program for our maintenance and ops people, and provide N95’s for the others to wear voluntarily.
We had an employee come in a couple of months ago with a half-face respirator, acid-gas cartridges, and the dust caps snapped on the outside. We explained why he couldn’t wear it at work, no exposure in his job, and his response was that the oil field supply store in town told him it would protect him from everything. 🤦🏻 The cartridges were about 5 days old at that point.
Why would anyone put a yellow cartridge on a half face respirator? Because you can…🤯
Your absolutely right.